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The Voice of Betsy Seals
If there is one thing we can always count on, it’s that the Centers for Medicare & Medicaid Services (CMS) will keep us on our toes!
While the industry patiently awaits the Final 2018 Medicare Marketing Guidelines (MMG), learn which draft guidelines could have a huge impact on the industry if made final.
Agent compensation for Medicare Advantage has changed drastically since the implementation of the Medicare Improvements for Patients and Providers Act (MIPPA) of 2008. MIPPA included regulations, for the first time, around Agent/Broker Commission – among many other things. The goal of implementing commission requirements was to ensure there was a level playing field between plans by implementing the Fair Market Value (FMV) limits, thereby removing the incentive for agents/brokers to enroll a beneficiary into the top-paying plan or to churn beneficiaries from one plan to another. Rather, the goal was to ensure the beneficiary was enrolled in the plan that best fit his/her needs.
There were several significant changes released in the 2016 Medicare Advantage & Part D Medicare Marketing Guidelines (MMGs), all of which communicate the same consistent message from the Centers for Medicare & Medicaid Services (CMS), the focus is on the beneficiary.
CMS Releases the 2015 Audit Protocol: Critical Next Steps to Avoid Becoming A Casualty of Reasonable Expectations
On February 12th, CMS released the 2015 Audit Protocol. The question on everyone’s mind is — what does this mean for 2015? Well, it means a few things. Outlined below are some of the most impactful changes, as well as the “why” behind the change, and the trends that continue to emerge.
When it comes to auditing throughout the Organization, the truth is that much of the responsibility often falls directly on the Compliance Department. This can be due to many factors, such as lack of resources or lack of cross-functional expertise. However, one of the CMS Compliance Program requirements is that the Compliance Program itself is audited annually. Fulfilling the requirement to annually audit the Compliance Program can present an issue for some Organizations due to the fact that Compliance Department self-auditing does not fulfill the requirement, and there may be no other department within the Organization with the expertise to conduct the review.